SEC Comment Letter for PharmaCyte Biotech, Inc. (PMCB) (CIK 0001157075) (PMCB) — Jun 6, 2011
PharmaCyte Biotech, Inc. (PMCB) (CIK 0001157075)
Date: June 6, 2011 · CIK: 0001157075 · Accession: 0000000000-11-034585
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-68008
Letter
June 3, 2011 Ms. Patricia Gruden Chief Executive Officer Nuvilex, Inc. 7702 E. Doubletree Ranch Road, Suite 300, Scottsdale, AZ 85258
Re: Nuvilex, Inc . Form 10-K for the Year Ended April 30, 2010 Forms 10-Q for Fiscal Quarters Ended July 31, 2010 and October 31, 2010 File No. 333-68008
Dear Ms. Gruden:
We have reviewed your April 27, 2011 response to our February 15, 2011 letter as well as your amendments filed on April 26, 2011 to the above referenced filings and have the following comment.
Please respond to this letter within ten business days by amending your filings or by advising us when you will provide the requested response. If you do not believe the comment applies to your facts and circumst ances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORR ESP that keys your response to our comment.
After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
Form 10-Q/A for Fiscal Quarter Ended July 31, 2010 Form 10-Q/A for Fiscal Qu arter Ended October 31, 2010 Item 4T. Controls and procedures, page 6
1. Your Item 4T disclosures do not comply w ith the language in Item 307 of Regulation S- K. You included reports on your internal c ontrol over financial reporting under item 4T of your referenced filings. A discussion of whether or not your certifying officers evaluated your disclosure c ontrols and procedures, as defined in Exchange Act Rules 13a-15(e) and 15d-15(e) at the end of the periods covered by your reports is however not included. Please amend your July 31, 2010 and October 31, 2010 quarterly filings to definitively state whether your disclosure c ontrols and procedures were evaluated and found effective or ineffective at the end of the periods covered by the reports. Please reference the Exchange Act Rules 13a-15(e) and 15d-15(e) in your re vised disclosures.
Ms. Patricia Gruden Nuvilex, Inc. June 3, 2011 Page 2 You may contact Ibolya Igna t, Staff Accountant at (202) 551-3656, or Gus Rodriguez, Accounting Branch Chief, at (202) 551-3752 if you have questions regarding the comment. In this regard, do not hesitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
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June 3, 2011 Ms. Patricia Gruden Chief Executive Officer Nuvilex, Inc. 7702 E. Doubletree Ranch Road, Suite 300, Scottsdale, AZ 85258 Re: Nuvilex, Inc . Form 10-K for the Year Ended April 30, 2010 Forms 10-Q for Fiscal Quarters Ended July 31, 2010 and October 31, 2010 File No. 333-68008 Dear Ms. Gruden: We have reviewed your April 27, 2011 response to our February 15, 2011 letter as well as your amendments filed on April 26, 2011 to the above referenced filings and have the following comment. Please respond to this letter within ten business days by amending your filings or by advising us when you will provide the requested response. If you do not believe the comment applies to your facts and circumst ances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORR ESP that keys your response to our comment. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Form 10-Q/A for Fiscal Quarter Ended July 31, 2010 Form 10-Q/A for Fiscal Qu arter Ended October 31, 2010 Item 4T. Controls and procedures, page 6 1. Your Item 4T disclosures do not comply w ith the language in Item 307 of Regulation S- K. You included reports on your internal c ontrol over financial reporting under item 4T of your referenced filings. A discussion of whether or not your certifying officers evaluated your disclosure c ontrols and procedures, as defined in Exchange Act Rules 13a-15(e) and 15d-15(e) at the end of the periods covered by your reports is however not included. Please amend your July 31, 2010 and October 31, 2010 quarterly filings to definitively state whether your disclosure c ontrols and procedures were evaluated and found effective or ineffective at the end of the periods covered by the reports. Please reference the Exchange Act Rules 13a-15(e) and 15d-15(e) in your re vised disclosures. Ms. Patricia Gruden Nuvilex, Inc. June 3, 2011 Page 2 You may contact Ibolya Igna t, Staff Accountant at (202) 551-3656, or Gus Rodriguez, Accounting Branch Chief, at (202) 551-3752 if you have questions regarding the comment. In this regard, do not hesitate to contact me, at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant